Labeling

April 22, 2001

Jen ---very well put i like your fact giving in this e-mail ! because you

are right in the end what an inspector says is the bottom line sometimes i

see what i want and believe in my thoughts strongly . the main reason i do

not see saponified oils of .....as deceptive is when i first started that is

how i was taught now knowing saponification can mean many different things

opens my eyes will i change it right away Allah kows best but you have peaked

my interest LOL !! seriously if i ever thought i was deceiving people or that

my ideas where misleading in a harmful way (because people i know say lye hum

let me try the glycerin soap) i would stop, being on this list makes me see

people can be offened by what i see as harmless. i really see it as

saponifying and prefered it people where not scared . think about the names

used for many different ingredients don't sound at all like their common

names but the INCI has a myriad of cooky names for everything. i really

don't like arguing and i am by nature very mild mannered (lol) unless like

many of us i am provoked--have a wonderful day --tamika

April 22, 2001

Jen-lol! i have seen that at B & BW alot smart guys(or girls) the declaration

thing question can you name for me (because i need ot know) the top five

(gurl parts LOL) irritants used in toiletries. common names please (i don't

have big books with names lol ) -thank you in advance-tamika

April 22, 2001

one correction Tamika...if you make cosmetic claims in any literature,

in your sales pitch or on a website you are indeed constrained to

follow the regulations - it's NOT just about claims on the label - the

FDA interprets ANY advertising or promotion as being extentions of

your label.

Hey, if you want to label your soaps in a deceptive manner because it

sounds nicer, go ahead...just don't blame me when the FDA decides

they've had enough of the cottage industry and brings in regulations

like they're trying to do in Canada. Interpret the rules any way you

want, but just remember, at the end of the day, the only

interpretation that matters is that of the FDA inspector.

Jules

> i don't object to using sodium hydroxide as an ingrdient name i

like the

> way saponified oils of sounds and in my opinion (which is how this

started

> when i gave advice to someone about opening up a shop which branched

of to

> the labeling issue) again in MY opinion it is straight forward . you

and some

> others heck maybe many others see it different but the government

does not

> say when you label you must label like this or that unless you make

cosmetic

> claims on the prominent label (in reference to soap) i don't write

laws i try

> my best to interperet the meanings . and the bottom line is unless i

make

> cosmetic claims no one can tell us how to label our

> soap. that is the beauty of living and working in america free

enterprise.

> happy soaping--tamika

April 22, 2001

but just remember, at the end of the day, the only

interpretation that matters is that of the FDA inspector.

Hi,

It doesn't matter what you read on a website, Jules is correct.

In the field the inspector is God - what they say goes and then you get to

defend yourself later on. But in the meantime they can basically close you down

by doing the following: fine you, force a product recall, sieze your goods, and

all kinds of other not so nice things.

If the inspector says your labels are incorrect then they are incorrect

period. Then your product will be not only considered mislabeled but also

adulterated.

The soap exemption, (not in too much favor with the FDA presently), does

not give a blanket exemption where anything goes. It is very difficult to work

within the boundaries which are soap - it cleans - no label required. It

doesn't include soap - look at all the goodies I put in there for moisturizing

benifits and this makes me better than a syndet bar label.

You also have to be cautious of what is called an Implied Benifit. If you

make a soap, no ingredient listing, but say it contains Shea Butter then there

is a percieved benifit by the customer that Shea Butter does something other

than clean - you have now crossed into the arena of cosmetic.

Now if all of this isn't enough to tick everyone off - here is another

issue - if you

do label then there are certain colours that are not allowed for use on mucous

membranes, (gurl parts).

Jen

April 22, 2001

As-salaamu Alaikum Tamika,

" because you are right in the end what an inspector says is the bottom line "

This gives you something to think about, hunh?

Khadiyja Y. Ali

Shades of the Nubian

www.shadesofthenubian.com

Featuring Shea Butter Bath & Body Essentials

(888) 43-NUBIAN

Take time out to enjoy the experience!

Re: Re: labeling